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HMRC internal manual

Capital Gains Manual

Migration of companies: changing a company's residence: 15/3/88-29/11/93

A company incorporated in a country outside the UK will only have been resident in the UK if the central management and control of the company has been exercised in the UK. In the period from 15 March 1988 to 29 November 1993 such a company can migrate by transferring its central management and control outside the UK.